Assure 360

The HSE’s new risk assessment guidance, and where it misses the point

Written by Nick Garland on 20/04/2022
 

The Health and Safety Executive (HSE) – or rather its Asbestos Network – is about to release some new guidance on non-asbestos risk assessments. Regular readers will know that this is an area very close to my heart. However, as the guidance stands I’m concerned that it will actually set back the industry’s understanding of the process.

The Asbestos Network starts well, explaining that risk management is about taking practical steps to protect people from real harm and suffering, rather than just bureaucratic back covering. It also states that risk assessment should focus on reducing significant risks, and not creating a totally risk-free situation.

The guidance goes on to identify the difference between everyday risks, standard risks and site-specific risks.

Everyday risks

These are those areas that we all experience all of the time. Examples would be getting in or out of the van, driving to the site, preparing lunch and so on. If the task at hand will not change the risk associated with the hazard, then we can ignore these for the purposes of a risk assessment.

Standard risks

These are incredibly routine, every-job situations that can be dealt with using a standard company approach. Examples might include:

  • Manual handling – waste transportation to the skip via a wheelie bin
  • Working at height – building a two-metre tall enclosure, requiring short step ladders
  • Biological hazard (e.g. leptospira bacteria) – wearing of gloves, no smoking on site, hygiene and welfare

These standard approaches can all be detailed in the standard operating procedures (SOPs), and need not be re-assessed with every project.

Take as an example the removal of a one-metre squared asbestos insulating board (AIB) panel, from eye level in a social housing bike store, 10 miles from your HQ. This incorporates some standard everyday risks – a manual handling hazard, working at height (building the enclosure), and Leptospirosis – but we don’t need to spend much time thinking about it as they’re all entirely routine.

Site-specific risks

This is the area that we should be focusing on. Site-specific risks fall into two categories: everyday and standard risks that have somehow been increased or changed because of the job, and new hazards introduced because of the task or location.

By just revising a couple of aspects in the above example, we can see how site-specific risks might completely alter the nature of the job. Imagine we’re removing the same AIB panel, but now at four metres above ground, and 300 miles from the office. Several things change. Driving that kind of distance towing a decontamination unit (DCU) is no longer round the corner, obviously. You’ll also need different methods to physically get to the panel, which may well affect the physical handling.

These changes must be assessed and new control measures designed. Breaks for the driving? A two day job with digs? What’s certain is that working at height now means you need a scaffold tower, and operatives with PASMA training. The manual handling (lifting equipment up to height, and the AIB down to the ground) will also be much more complex, and require appropriate controls.

Anything New?

This guidance confirms the relatively common aspirational goal of returning to the site just ahead of the official start date as best practice. Wherever reasonably practicable you should re-assess the hazards – has anything changed? Is the location of the DCU still appropriate? Are there any new hazards?

To underline the importance of recognising that things change, the guidance also stresses that the supervisor should be conducting their own daily risk assessments. Essentially, a competent experienced supervisor should not blindly follow an out of date method, just because that’s what was written. You may know this practice as point of work risk assessment – in their wisdom, the Asbestos Network terms it ‘dynamic risk assessment’.

To be clear, I fundamentally agree with all of this approach, but I have some relatively minor objections to a couple of specific examples:

Working at height Mobile tower required to access asbestos-containing material (ACM) for removal. PASMA trained operatives (named) to erect, with hold point in plan of work (PoW) and checked by supervisor to ensure this is correctly built prior to removal activity
Confined space Purging air to be introduced to facilitate works with trained site team, escape set provision and continuous gas monitoring in place throughout confined space (CS) working

My problem with the first example is on a practical point – the chances of knowing that Steve the PASMA-trained operative will be assigned to a particular job in a number of weeks’ time is remote to say the least. Naming the specific operative shouldn’t be necessary.

The second is a lazy example that encourages a very poor attitude to confined space. It falls into the trap of taking a standardised approach that fails to recognise the specifics of why a space is confined, and what the exact risks are. In some cases, rolling out these standard controls would make matters worse, as I’ve previously explained in my analysis of the Confined Spaces Guidance.

This is the example they should have given:

Confined space (due to risk of reduced oxygen levels)  Purging air to be introduced to facilitate works with trained site team, escape set provision and continuous gas monitoring in place throughout CS working

There is also a final paragraph on quantitative risk assessments (i.e. risk assessments (RAs) with numbers), which states that they are not needed. The logic is that they are ‘only required to prioritise the controls’, and that because it’s a licensed activity you will be doing all of the controls. It is difficult to argue against this, but there may be a practical issue, as many PC clients will not recognise a RA without the quantification element.

What is the purpose of a risk assessment?

Other than these ‘minor’ points, the guidance contains sound advice. But I have a more fundamental issue with this as a standalone separate piece of guidance.

A simple way to think about risk assessment is that it’s like an exam. There is the question, and an answer – but you will also have your workings out. In the world of construction and asbestos – the method statement (how you’re going to do the job) is the ‘answer’, and the risk assessments are your workings out.

The answer is crucial, but the only way you can be sure to get the ‘right’ answer is after you’ve done the workings out. Far too many people make the mistake of seeing risk assessments and method statements as two separate exercises – or even worse two separate documents – and that’s exactly the trap that the current guidance as written is ushering us into.

Instead, the biggest section of the guidance should be focusing on how to translate the identified controls into the method itself. This ‘lost chapter’ in your method statement should have a work area set up section talking about using the hoist to lift the negative pressure unit (NPU) into position. It should be detailing the bagging of the AIB on the scaffold, and then the lowering of it to an operative on the ground. If indeed there is a confined space due to oxygen depletion, it should detail exactly how and when you will be introducing purging air (before you even start building the enclosure, I would presume).

What the current document tells us to do is complete a site-specific risk assessment (good), streamline it so that readers can focus on what is important without the fog of the mundane (great), and check regularly that it’s still valid (brilliant). But not once does it mention the reason we are doing this in the first place – writing a method that the employees can follow that will get them home safely (fail).

Tweet  Share on Facebook  Share on Linkedin
"The Assure 360 database allows us to take a top level view of all of our asbestos removal contractors, directly comparing and contrasting them against each other."
Richard Bennion, Asbestos Compliance Manager, Royal Mail Group